PRIVACY POLICY
This Privacy Policy (hereinafter referred to as the "Policy") governs the data processing practices of AYENK LLP, BIN 180 440 039 847 (hereinafter – the "Company"), with respect to the data it may collect via the Ilumee mobile application (hereinafter – the "Application") and the website located at https://ilumee.ai (hereinafter – the "Website"). The Company processes user data in accordance with the legislation of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V "On Personal Data and Their Protection", as well as international treaties ratified by the Republic of Kazakhstan. This Policy has been developed in accordance with these legal norms.
By using the Application and/or Website, the User agrees to the terms of this Privacy Policy and the associated data processing practices. If the User does not agree with the terms, they must cease using the Application and/or Website.
The purpose of this Policy is to ensure the proper protection of User information, including personal data, from unauthorized access and disclosure.
This Policy, along with other official documentation of the Application and/or Website and the legislation of the Republic of Kazakhstan, governs the collection, storage, dissemination, and protection of User information. In the event of any inconsistencies between this Policy and other documents, this Policy shall prevail.
Users should be aware that links within the Application or Website may redirect them to external websites or applications operated by third parties. The Company does not control how data is collected on such third-party platforms. In these cases, the privacy policies of the respective third parties will govern the use of User data. The Company bears no responsibility for data submitted by the User to third parties.
If the User logs in using third-party authentication services (e.g., Facebook), the Company may receive additional profile information that the User has made available for third-party access.
1. DEFINITIONS
1.1. The following terms are used in this Policy:
1.1.1. Website Administration – Authorized personnel of AYENK LLP responsible for organizing and/or conducting the processing of confidential data, as well as determining the purposes, scope, and methods of such processing.
1.1.2. Confidential Data – Data submitted by the User via contact forms or service requests, Cookies, and data automatically collected during Website usage, including but not limited to IP address, device information, etc.
1.1.3. Personal Data – Any information relating to an identified or identifiable individual, recorded on electronic, paper, or other tangible media.
1.1.4. Processing of Personal Data – Any operation or set of operations performed on personal data, with or without automated means, including collection, recording, systematization, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, or destruction.
1.1.5. Confidentiality of Personal Data – The obligation to prevent disclosure of personal data without the subject’s consent or another legal basis.
1.1.6. User – Any individual accessing or using the Application and/or Website via the Internet.
1.1.7. Website – The site located at https://ilumee.ai.
1.1.8. Application – The Ilumee mobile application.
1.1.9. Cookies – Small data files stored on a User’s device by the web server and sent back with subsequent requests.
1.1.10. IP Address – A unique address assigned to a device on the Internet.
2. SCOPE OF THE POLICY
2.1. This Policy outlines the obligation of the Website Administration to ensure the confidentiality of data submitted by Users through various forms on the Website, including service connection requests.
2.2. Confidential data may include, at the discretion of the User: name, phone number, and email address of the legal entity. If the User submits their own personal data instead of legal entity data, the Company shall protect such data in accordance with applicable laws.
2.3. The Website and Application may collect data via web analytics tools and advertising technologies, including:
IP address;
Cookie data;
Browser type and version;
Operating system;
Access time and time zone;
Page URL being visited.
2.3.1. Disabling Cookies may affect access to certain Website sections.
2.3.2. The Administration may collect statistical data to resolve technical issues and prevent fraud.
2.3.3. Data will be securely stored and not disclosed, except as outlined in this Policy or under the laws of Kazakhstan.
2.3.5. The Company may share User data with affiliates, including those outside Kazakhstan, provided they adhere to this Policy.
2.3.6. The Company may disclose User data to unaffiliated third parties only:
With the User’s consent;
To comply with legal obligations;
To address technical or security issues;
To protect the rights and safety of the Company and its Users.
3. EFFECTIVE DATE AND AMENDMENTS
3.1. This Policy takes effect indefinitely upon publication. It will remain valid until replaced by a new version published on the Website.
3.2. The current version of the Policy is available at https://ilumee.ai. The Company may amend this Policy as needed. Updated versions will be published on the Website and/or Application as notice to Users.
4. PURPOSES OF DATA PROCESSING
4.1. User data is processed for the following purposes:
To process User service requests and interact with legal entities, individuals, or entrepreneurs regarding documentation and service contracts;
To provide technical support and improve Website performance.
5. METHODS AND DURATION OF PROCESSING
5.1. Data is processed using legal means, with or without automation, for an indefinite period.
5.2. The User consents to indefinite data processing.
5.3. Data may be provided to government authorities under applicable Kazakhstani law.
5.4. The Administration is responsible for ensuring data confidentiality, security, and compliance with legal standards.
5.5. In the event of data loss or breach, the User will be informed.
5.6. The parties shall take joint action to mitigate any resulting damages.
6. OBLIGATIONS OF THE PARTIES
6.1. The User shall:
Provide accurate data when using the Application and/or Website;
Update data as necessary;
Obtain consent from third parties if submitting their data.
6.2. The Administration shall:
Use confidential data only for purposes stated in Section 4;
Maintain confidentiality and not disclose data without prior written User consent, except as otherwise permitted;
Take reasonable security measures in accordance with applicable law.
7. LIABILITY
7.1. The Administration is not liable for disclosure if:
The data became public before disclosure;
The data was obtained from a third party;
The data was disclosed with User consent.
7.2. The User shall indemnify the Company for damages resulting from third-party claims due to submission of data without proper consent or submission of inaccurate data.
8. DISPUTE RESOLUTION
8.1. Before filing a claim in court, the User must submit a written complaint for voluntary dispute resolution.
8.2. The recipient shall respond within 30 calendar days.
8.3. If unresolved, the dispute shall be referred to a court under Kazakhstan law.
8.4. This Policy and related legal relations are governed by the laws of the Republic of Kazakhstan.
9. ADDITIONAL PROVISIONS
9.1. Personal data processing is governed by the agreements concluded between the Company and its clients.
9.2. The User may revoke their consent at any time by submitting a written request to the Company.
9.3. Users have rights under Chapter 4 of the Law of Kazakhstan “On Personal Data,” including access, correction, blocking, or deletion of personal data.
9.4. Kazakhstani law governs all matters arising from this Policy.
9.5. The Company may amend this Policy without User consent.
9.6. The new version is effective upon publication unless otherwise stated.
9.7. The User is responsible for reviewing updates to the Policy.
9.8. Questions or suggestions should be submitted via the Website.
9.9. The Policy is published at: https://ilumee.ai